Uganda Tourism Visa Vis Oil Exploration

THE PROPOSED EARLY PRODUCTION SYSTEM - ISSUES FOR DISCUSSION DURING THE PUBLIC HEARING -Source UWA www.uwa.or.ug

Uganda Wildlife Authority acknowledges the fact that conservation and development can co-exist as long as the two are conducted with strict adherence to the set standards, rules and regulations. The Authority therefore does not oppose oil development within the Albertine graben that also coincides with the protected areas. However Uganda Wildlife Authority recommends that this activity be conducted with minimal impacts to the wildlife and the protected areas.

Uganda Wildlife Authority being one of the key stakeholders in the oil development process, was availed the EIS for review and comments. Detailed comments were sent to NEMA for consideration in the approval process of the EIA but would like to further stress issues for discussion during the proposed public hearing. Broadly the following areas need to be addressed

1. Waste management: Given that this activity of oil development is new in this country with some of the waste generated not known it is critical that the study provides a detailed waste management plan which specifies the source, type of waste and disposal methods. The plan should be provided now and be approved with the EIS.

Further still, the report mentions that heavy contaminated waste will be sent for disposal at approved sites in Uganda. The sites should be identified and approved with this EIA.

The document only identifies the plans to be developed by Tullow in future. However all major plans such as Waste (all wastes) management plan, emergency plans for management of oil spills and water pollution, traffic management plan, construction site management plan and locations of camps inside the reserve, integrated conservation management plan among others should be part of the basis for NEMA to approve this EIS.

2. Location of the EPS vs Degazzettement:

The EIA identifies a site within Kabwoya Wildlife Reserve for the construction of the EPS. UWA's preferred position is the EPS be located outside the reserve. However if the EPS has to be in the reserve, then strict compliance to the mitigation measures must be observed. The EIA goes further to proposes degazzettement of the reserve to allow this activity to take place. Since oil is a non-renewable resource UWA contends that it is not necessary to degazette the reserve in favour of oil. Instead oil production should be used to enhance conservation in the area and boost tourism so that for sustainability reasons, tourism will act as source of income once oil is exhausted. The oil company should therefore work out modalities with UWA in accordance with the Wildlife Act and any other relevant laws on how to operate in the Reserve. In any case we cannot degazette all protected areas where oil is found.

Oil visa vis Tourism Sustainability:The life of the EPS is estimated at 15-20 years but tourism has the potential to continue for hundreds of years. There is need therefore for the developer to enter into a compensation agreement with UWA and other stakeholders to compensate for the lost income and be able to support conservation in the area.

3. Pollution The potential risk of pollution especially water sources such as the River Howa valley/water system that is mainly a source of water for the wildlife especially during the dry season. The river also drains into Lake Albert and therefore this development will have a bearing on the water resources for fishing and domestic use by the fishing community as well as affecting the water cycle in the Area

4. Monitoring compliance

The capacity to regularly monitor the impacts and ensure mitigation measures are implemented will remain a big challenge. There is need to set aside funds for the capacity of staff of relevant agencies in this regard.

Recommendations:We need to set up a conservation fund to ensure sustainability of the conservation activities in areas where oil exploration and development is taking place. Specifically the funds should be used:To supplement the dropped revenue from tourism as a result of oil development,

To create corridors for animal movement through direct land purchase To create buffer zones as dispersal areas for wildlife in light of the oil development activities To support human activities that are compatible with conservation in the buffer zones and wildlife corridors that will be established. To support implementation of mitigation measures that the oil companies may not implement To support development of capacity both human and logistical, to monitor the impacts of oil development activities and ensure mitigation measures are implemented In this regard therefore we further recommend:

A specific percentage from the Environmental Fund (already provided for in the Oil and Gas Policy) be set aside for the conservation fund A specific percentage from the oil company into the conservation fund as part of their corporate social responsibility towards conservation.

The public hearing on the proposed established of an oil Early Production System (EPS) in Kabwoya Wildlife Reserve, which took place on 29th July concluded with Ugandans calling for promotion of environment-friendly practices that will ensure that conservation continues even as oil production begins within one of Uganda's popular protected areas.

The National Environment Management Authority (NEMA) organized the hearing after the public expressed major concerns with regard to the Environmental Impact Assessment, which was submitted by Tullow Oil - the company behind the plans to establish the EPS in the reserve.

Ugandans called for equitable sharing of the oil revenue, and expressed keen interest in seeing key constituents such as wildlife conservation and the local communities of Bunyoro benefit significantly from this revenue.

Sam Mwandha, the Director for Conservation at Uganda Wildlife Authority (UWA) said a Conservation Fund should be established that will be used to fund monitoring and evaluation activities as well as help in implementing mitigation measures that Tullow Oil may fail to implement.

Tullow Oil opted to construct the EPS in Kabwoya Wildlife Reserve after confirming that the other alternative location would push the costs of production too high.

The EIA report proposed that the Kabwoya Wildlife Reserve be degazetted in order to accommodate the oil production activities, but this was flatly rejected.

We want the public to know that oil production will last a limited time, but the biodiversity in the reserve will remain and we should protect it," Mwandha said at the hearing, further observing that, "There will be big potential for pollution yet the EIA report was short on recommendations as far as mitigation will go." He also mentioned that monitoring remains a big challenge, and it will require all the relevant government agencies to get together to establish strong monitoring mechanisms.

The Deputy Prime Minister of the Bunyoro Government said that government should ensure that there is a concrete plan for opening up new areas where displaced wildlife will find refuge, as well as plans for resettling the people who will get displaced.

Former Member of Parliament for Rubaga North, and a renown environmental crusader, Ken Lukyamuzi observed that the planned EPS (oil refinery) would greatly impact on the ecosystem in the wildlife reserve and all efforts should be made to protect its beauty.

Speaking on behalf of the Honorary Wildlife Officers, Dr. Arthur Mugisha said as much thought should be put into the ecological costs of oil production as the economic costs, and concerted efforts should e made to preserve the ecology of the wildlife reserve.

The Member of Parliament for Bugaya County, Hon.Patrick Baguma said it is necessary to do a cost-benefit analysis before a license for establishing an oil refinery in a wildlife reserve is granted. "What shall we lose in terms of the flora and fauna (biodiversity) compared to oil?" he asked rhetorically.

However, the 2nd Deputy Prime Minister and Minister of Public Service, Hon Henry Kajura who also hails from Bunyoro, told participants in the public hearing that Ugandans should now concentrate on working out recommendations on how to get the oil flowing without negatively impacting the wildlife reserve.

"Let us move forward; we need this resource for development and for our infrastructure such as schools, roads and communications," he implored.

The Permanent Secretary in the Ministry of Energy and Mineral Development, Kabagambe Kaliisa said that whether at central or local government level, oil revenue will be used to create wealth and put infrastructure in place, create knowledge, educate the people and develop the country.

The Minister of State for Water and Environment, Hon Jessica Eriyo however counseled that the issues discussed at the public hearing should be taken seriously and integrated into program activities by all the concerned parties.

"Oil and gas will meet our country's needs for a long time, but the risks to biodiversity are also likely to increase. The challenge is to have a strong voice for biodiversity conservation and reduce air and water pollution," Hon. Eriyo said.

She observed that there is need to harness the opportunities for conservation, and pointed out that when the oil is finished we still need to have our ecosystems in good shape.

"Biodiversity conservation is an integral component of sustainable development," she observed, adding, "I therefore urge Tullow Oil and other organizations to ensure that environmental considerations are in all their activities including improvement of community livelihoods."

By the time the public hearing ended after nearly 10 hours of discussing and debating, consensus was reached to the effect that oil exploration and production should not be at the expense of biodiversity conservation.

Tullow Oil acknowledged that the loss of plants and displacement of animals will be inevitable during construction of the EPS but promised to keep the area affected as small as possible.

They also promised that after construction of the EPS they would ensure that all the areas around the EPS are returned to the same state as before.

STATEMENT SUBMITTED BY HONORARY WILDLIFE WARDENS TO THE PUBLIC HEARING ON PROPOSED EARLY PRODUCTION SYSTEM EPS DUE 29TH JULY 2008 , HOIMA, UGANDA.

The Honorary Wildlife Wardens reviewed the EIA Study Final Report (March 2008) and the Environmental Management Plan and presents the following issues for deliberation at the public hearing session.

1. The Oil production with respect to the protected Areas in the Albertine Rift

The Honorary WildLife Wardens support the oil production in the Albertine Rift for the sustainable development of Uganda. It notes that the oil rich zone in the Albertine Rift is also a rich biodiversity zone for Uganda and the global community. Further, it notes that oil production will be undertaken alongside the biodiversity conservation and management objectives for Uganda and the global community. Honorary WildLife Wardens wish to take the opportunity of this Oil development to call upon the Country to manage the oil production for the benefit of the country with minimal impact on the rich biodiversity. It further calls upon UWA and other Lead Agencies ( NFA, NEMA, Wetlands Department, Water Resources Department, among others) to provide the required technical leadership and cooperation in ensuring that oil business does not undermine the integrity of biodiversity resources and integrity of the Protected Areas in the Albertine Rift. In this regards, the Honorary Wildlife Wardens request that the Agencies mentioned above develop and publish a Policy and Guidelines for management of biodiversity and protected areas in the Albertine Rift to address Oil production in the region. It is further recommended to develop and publish the proposed Policy and Guidelines before oil production starts, i.e., before end of 2008.

2. The Proposed Establishment of EPS in Kabwoya Wildlife Reserve

The Honorary Wildlife Wardens, having reviewed the Selection criteria for constructing the EPS in Kabwoya Wildlife Reserve (section 1.5 page VIII of the EIA Report) and the likely impacts of the location (Section 1.7, page XI of the EIA Report) and notes the following:

a) the selection criteria assessing the suitability of the Kabwoya Wildlife Reserve is weak in considering the environmental impacts; the criteria favours the capacity of Tullow to manage environmental effects as opposed to identifying the environmental impacts themselves.

b) approximately 500mX500m size of land within the Kabwoya Wildlife Reserve will be utilized for physical construction of the EPS. Additional land will be utilized to service the facility in form of transport, housing, etc;

c) Kabwoya Wildlife Reserve is national heritage under custodian of Board of Trustees of Uganda Wildlife Authority with management responsibility entrusted through the Trustees to the Uganda Wildlife authority; and

d) Kabwoya Wildlife Reserve presently is relatively less disturbed, human use of the reserve is minimum (livestock grazing and fishing activities are predominant human activities) and is evaluated as largely natural wilderness for the good of biodiversity conservation and future opportunities for tourism and other permissible biodiversity uses.

3. Issues of Concern

3.1 Establishment of EPS in Kabwoya Wildlife Reserve

The EIA study should review the criteria for selecting the Kabwoya Wildlife Reserve for EPS with the view to strengthen the assessment of likely environmental and biodiversity impacts of the EPS. This will generate sufficient mitigation measures should the decision to establish the EPS in the Reserve be upheld. This recommendation should be mandatory before NEMAs decision on the EIA report is taken.

3.2 Role of managing Authority (UWA)

UWA as the Lead agency responsible for Wildlife and Wildlife Protected Areas should enjoy participation status in the Oil business to the level that guarantees its access and influence on the following decisions:

a) Proposed establishment of EPS in the Wildlife Reserveb) Approving the Environmental Management Plan as it relates to aspects of managing the Wildlife and Wildlife Reservec) Determining the loyalties and accruing benefits and their administration in relation to use of Wildlife areas.d) Guaranteeing the integrity of Wildlife Protected Areas

In order for UWA to satisfactorily exercise its mandate, UWA must posses internal capacity or have means to access capacity to monitor and supervise Oil business in the Albertine Rift. We recommend that the Oil business take this responsibility of equipping UWA with the capacity to manage business related Oil industry or avail resources for UWA to acquire and deploy such capacity.

Accordingly, the EAI report should be revised to reflect the Status and role of UWA in the Oil business in order to address these issues.

3.3 Optimizing the benefits from Oil business

Under the Wildlife Act, the UWA is mandated to generate revenues from the Wildlife and to invest these revenues in managing the Wildlife and Wildlife estate. The Wildlife Policy envisage future scenario when UWA's dependence on Government Treasury for financing its operations stops so that the organization is self financing.

Against this background, the Honorary Wildlife Wardens recommend that granting UWA authority to levy fees/loyalties and other charges to the Oil business as it relates to use of Wildlife estate. It is recommended that establishment of EPS and associated service facilities in Kabwoya Wildlife Reserve attract fees payable directly to UWA. This should be reflected in the economic analysis of the EPS before NEMA's decision on the EIA report is taken.

3.4 Securing/Guaranteeing security of Biodiversity and integrity of Protected Areas in the Albertine Rift

Further to the recommendation regarding development of Policy and Guidelines for Oil production in the Albertine Rift (section 1), Honorary Wildlife Wardens recommend the following measures for securing the integrity of Kabwoya Wildlife Reserve.

a) Reject the proposal to establish the EPS in the Wildlife Reserve on grounds of the gravity of its impact on the integrity of the Wildlife Reserve. Further, this proposal should be rejected on grounds of "no-harm" principle. Permitting establishment of EPS in the Wildlife Reserves sets a precedent that carries far reaching consequences and implications to the management to other protected areas in the Albertine Rift in light of Uganda's Oil industry.b) In the event that proposal to establish the EPS in the Wildlife Reserve is approved, the location selected should not be degazetted. We recommend that such operation should be permitted on leased land that reverts to UWA at the closure of Business. This recommendation is consistent with other businesses licensed by UWA (e.g. hotels) within Wildlife Protected Areas that operate under leased arrangements. Further, this recommendation will enable UWA implement recommendation #3.4.c) In the event that the proposal to establish EPS in Kabwoya Wildlife Reserve is accepted, we recommend that Tullow responsibility to clean up and restore the Kabwoya reserve after its operations wind up should be legally "bonded" and interests for such bond entrusted to UWA. This will ensure that clean up and restoration activities will be implemented after decommissioning the EPS.d) A time table for government of Uganda to ratify identified internal agreements (section 3.6.2 page 3-15 of EIA report) should be negotiated and committed before decision on the EIA report is taken.

4. Conclusion

Honorary Wildlife Wardens are conscious about the important role Oil industry is envisaged to play in the development of the Country and present these views in the best interest of sustainable development of Uganda.

Further, the Honorary Wildlife Wardens wish to take this opportunity to thank NEMA for permitting the presentation of this statement.

Sir/Madam Chair, the Honorary WildLife Wardens wish to assure you of their interest in this matter and to pledge their capacity to contribute to the current and future deliberations regarding management of Wildlife and Wildlife Protected Areas.

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